Inline XBRL Adopted Amendments PRA Supporting Statement.06-06-2019

SUPPORTING STATEMENT
FOR THE PAPERWORK REDUCTION ACT INFORMATION COLLECTION SUBMISSION
FOR INLINE XBRL FILING OF TAGGED DATA
ADOPTED AMENDMENTS

A.

JUSTIFICATION
1.

CIRCUMSTANCES MAKING THE COLLECTION OF INFORMATION
NECESSARY

In Release No. 33-10514,1 the Commission adopted amendments to require the
use of the Inline XBRL format for the currently required exhibit-only submission of
operating company financial statement information using the machine-readable (i.e.,
interactive) eXtensible Business Reporting Language (XBRL) format in Interactive Data
Files. These amendments will require operating companies, on a phased in basis, to
embed part of the Interactive Data File within an HTML document using Inline XBRL
and include the rest in an exhibit to that document. The amendments also have
eliminated the requirement for operating companies to post Interactive Data Files on their
websites. In addition, the amendments will make and have made certain other changes
that will not affect operating companies.2
The Inline XBRL requirements for operating companies will be phased in through
annual increments based on the category of filer status. Large accelerated filers that
prepare their financial statements in accordance with U.S. GAAP will be required to
comply in the first year of the requirements, followed by accelerated filers that prepare
their financial statements in accordance with U.S. GAAP in the second year and all other
operating company filers that are required to submit Interactive Data Files in the third
year. Operating company filers are permitted to file using Inline XBRL under the
amendments prior to their compliance date. Otherwise, filers continue to be required to
file the Interactive Data File entirely as an exhibit, as they do currently.
The amendments concern existing XBRL data rules that contain “collection of
information” requirements within the meaning of the Paperwork Reduction Act of 1995
(PRA). The title of the collection of information impacted by the amendments relating to
operating companies is “Interactive Data” (OMB Control No. 3235-0645).

1

Inline XBRL Filing of Tagged Data, Release No. 33-10514 (June 28, 2018) [83 FR 40846 (Aug. 16,
2018)]. The amendments were proposed in Release No. 33-10323 (Mar. 1, 2017) [82 FR 14282 (Mar. 17,
2017)] (Inline XBRL Proposing Release).

2

This supporting statement relates only to the amendments that will affect operating companies.

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2.

PURPOSE AND USE OF THE INFORMATION COLLECTION

The primary purpose of requiring the use of Inline XBRL format for the
submission of operating company financial statement information is to improve the
usefulness and quality of financial statement disclosure, and, over time, to decrease the
cost of preparing this information for submission to the Commission.
3.

CONSIDERATION GIVEN TO INFORMATION TECHNOLOGY

Responses under the Interactive Data File requirements are submitted to the
Commission electronically on its Electronic Data Gathering, Analysis, and Retrieval
(EDGAR) system in XBRL format. The public may access submissions on EDGAR
through the Commission’s Internet website (http://www.sec.gov).
4.

DUPLICATION OF INFORMATION

Interactive data format operating company financial statement information already
is and will continue to be required to be submitted to the Commission in traditional
format (i.e., HyperText Markup Language (HTML)) under existing requirements. When
the information is in traditional format, it cannot be used as effectively as when in an
interactive data format that a variety of software applications can recognize and process.
Interactive data format facilitates investor analysis of financial information and assists
issuers in automating regulatory filings and business information processing.
5.

REDUCING THE BURDEN ON SMALL ENTITIES

Requiring the use of the Inline XBRL format will affect all operating company
filers, including small entities, currently subject to the requirement to submit Interactive
Data Files in exhibit-only format. The Commission performed a Final Regulatory
Flexibility Act Analysis and estimated that there are approximately 1,163 operating
companies that are small entities subject to these requirements.
The amendments include different compliance schedules based on filer size and
use of accounting principles. Small entities that are operating companies will not be
subject to the requirements until year three of the phase-in. The different compliance
timetables will enable these filers to defer the burden of any additional cost, learn from
filers that comply earlier and take advantage of any increases in the quality or decreases in
the price of Inline XBRL preparation services or software that arise from expertise or
competition that develops prior to their phase-in. In addition, small entities, as all other
filers, will continue to have a 30-day grace period to make their initial Interactive Data
File submission. The elimination of the website posting requirement for all filers
consolidates and simplifies the compliance and reporting requirements for all filers with
respect to their Interactive Data Files.

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The Commission did not adopt other alternatives regarding small entities because
it believes that the long-term consistent use of Inline XBRL may reduce the time and
effort required to prepare XBRL filings, simplify the review process for filers and
improve the usefulness and quality of XBRL data, thereby benefiting investors, other
market participants, and other data users and potentially increasing the use of XBRL data.
The elimination of the website posting requirements is expected to decrease burdens on
all filers, including small entities.
6.

CONSEQUENCES OF NOT CONDUCTING COLLECTION

If the specified financial information were not required in interactive data format,
the information would be available through the Commission only in the traditional
format. Providing financial information in an interactive data format facilitates investor
analysis of financial information. In addition, the use of interactive data format assists
issuers in automating regulatory filings and business information processing. If
interactive data format information were required less frequently, less information would
appear in that format and, as a result, the Interactive Data File requirement would be less
likely to facilitate its intended purposes and achieve its expected benefits. Failure to
conduct the collection of information affected by the amendments could frustrate the
Commission’s intent to improve the usefulness and quality of, and, over time, to decrease
the cost of preparing the data for submission to the Commission.
7.

SPECIAL CIRCUMSTANCES
There are no special circumstances in connection with these amendments.

8.

CONSULTATIONS WITH PERSONS OUTSIDE THE AGENCY

The Commission issued a release soliciting comment on its PRA burden hour and
cost estimates and the analysis used to derive these estimates.3 Comments on the
Commission’s releases are generally received from filers, investors and other market
participants. In addition, the Commission and staff participate in an ongoing dialogue
with representatives of various market participants through public conferences, meetings
and informal exchanges. The Commission considers all comments received. The
Commission did not receive any comments that provided quantitative estimates
concerning its PRA analysis and burden estimates of the amendments. A copy of the
adopting release is attached.
9.

PAYMENT OR GIFT TO RESPONDENTS
None.

3

Inline XBRL Proposing Release, supra note 1.

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10.

CONFIDENTIALITY

All documents submitted to the Commission under this collection of information
are available to the public via the EDGAR system.
11.

SENSITIVE QUESTIONS

No information of a sensitive nature, including social security numbers, is or will
be required under this collection of information. The information collection does not and
will not collect personally identifiable information (PII). The agency has determined that
a system of records notice (SORN) and privacy impact assessment (PIA) are not required
in connection with the collection of information.
12/13. ESTIMATES OF HOUR AND COST BURDENS
The paperwork burden estimates associated with the amendments include the
burdens attributable to collecting, preparing, reviewing and retaining records. The
Commission adopted amendments to require the use of the Inline XBRL format for the
currently required exhibit-only submission of operating company financial statement
information in Interactive Data Files. These amendments will affect the Interactive Data
collection of information requirements by requiring operating companies, on a phased in
basis, to embed part of the Interactive Data File within an HTML document using Inline
XBRL and include the rest in an exhibit to that document. The Commission also adopted
amendments to eliminate the operating company financial statement information
Interactive Data File website posting requirement. These amendments also will affect
Interactive Data collection of information requirements. We believe that the actual
burdens will likely vary among individual companies based on the size of their
organization. For administrative convenience, the paperwork burden hour totals
presented have been rounded to the nearest whole number. The estimate of burden hours
is made solely for the purpose of the Paperwork Reduction Act. It is not derived from a
comprehensive or even a representative survey or study of the cost of Commission rules
and forms.
We continue to estimate that the Inline XBRL requirement for financial statement
information will result in an initial increase in the existing internal burden of XBRL
requirements (56 hours per response) by eight hours to switch to Inline XBRL. This
increase in burden would be borne only for the initial response that uses Inline XBRL.
We also continue to estimate that reductions in review time will result in a decrease of
two hours per response in the existing internal burden, beginning with the initial response

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and continuing on an ongoing basis.4 We further continue to estimate that the average
filer will incur a small increase in external cost of $5 per response (from $6,170 to
$6,175) on an ongoing basis, beginning in the first year of compliance for its phase-in
category. We previously estimated that there would be 38,705 responses per year by
8,601 filers.5 Based on more recent information on the number of filers, we estimate that
there will be 37,418 responses per year by 8,315 filers.6 Based on the number of filers
that we expect to be phased in during each of the first three years under the requirements,7
the number of filings that we expect those filers to make that will require interactive data
and the internal burden hour and external cost estimates per response discussed above, we
estimate that, over the first three years of the Inline XBRL requirements, switching to the
Inline XBRL format will decrease the aggregate average yearly burden of financial
statement information XBRL requirements by 20,455 hours of in-house personnel time8

4

Thus, for the initial response using Inline XBRL, we estimate that filers would experience a net increase in
internal burden of 6 hours (8 hours – 2 hours = 6 hours).

5

8,601 filers x 4.5 responses per filer = 38,705 responses per year.

6

We continue to estimate that there will be 4.5 responses per filer per year. 8,315 filers x 4.5 responses per
filer = 37,418 responses.

7

Based on staff analysis of Form 10-K, 10-Q, 20-F, and 40-F filings and amendments to them filed during
calendar year 2017, approximately 26% of filers were large accelerated filers and approximately 19% of
filers were accelerated filers. For purposes of this estimate, we assume that these percentages are
representative of the percentages of filers in different phase-in categories.

8

The first response is estimated to incur a net additional burden of six hours per response and the remaining
responses are estimated to incur a net decrease in burden of two hours per response. The calculation below
considers the aggregate average yearly change in internal burden incurred by each of the three categories of
filers during the first three years of the Inline XBRL requirements. Filers that are phased in during year two
are assumed to incur no change in burden during year one. Filers that are phased in during year three are
assumed to incur no change in burden during years one and two.
Filers phased in during year one: 8,315 x 26%. Average yearly change in internal burden per filer: [6 +
(3.5 + 4.5 + 4.5) x (-2)] / 3 = -6.33 hours. Aggregate average yearly change in internal burden for filers
phased in during year one: 8,315 x 26% x (-6.33 hours) = -13,685 hours.
Filers phased in during year two: 8,315 x 19%. Average yearly change in internal burden per filer: [0 + 6 +
(3.5 + 4.5) x (-2)] / 3 = -3.33 hours. Aggregate average yearly change in internal burden for filers phased in
during year two: 8,315 x 19% x (-3.33 hours) = -5,261 hours.
Filers phased in during year three: 8,315 x 55%. Average yearly change in internal burden per filer: [0 + 0
+ 6 + 3.5 x (-2)] / 3 = -0.33 hours. Aggregate average yearly change in internal burden for filers phased in
during year three: 8,315 x 55% x (-0.33 hours) = -1,509 hours.
Aggregate average yearly change in internal burden: -13,685 - 5,261 - 1,509 = -20,455 hours.

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and increase the aggregate average yearly cost of services of outside professionals by
$106,640.9
The elimination of the operating company financial statement information website
posting requirement also is expected to reduce the paperwork burden. We previously
estimated that operating companies would incur an average of approximately four burden
hours per filer per year to post interactive data to their websites. Based on our updated
estimate of 8,315 filers, we estimate that the elimination of the website posting
requirement will decrease the aggregate average yearly burden on operating company
filers by 33,260 hours.10
We previously estimated the aggregate average yearly burden of the existing
XBRL requirements for operating companies as 2,167,480 hours of in-house personnel
time11 and $238,809,850 in the cost of services of outside professionals.12 Using more
recent information on the number of filers, the aggregate average yearly burden of the
existing XBRL requirements for operating companies would be 2,095,408 hours of inhouse personnel time13 and $230,869,060 in the cost of services of outside
professionals.14 We estimate that in the first three years of the Inline XBRL
requirements, the aggregate average yearly burden of XBRL requirements for operating

9

Filers are estimated to incur an additional $5 per response beginning with the first year of compliance for
their phase-in category. The calculation below considers the aggregate average yearly change in external
cost incurred by each of the three categories of filers during the first three years of the Inline XBRL
requirements. Filers that are phased in during year two are assumed to incur no change in external cost
during year one. Filers that are phased in during year three are assumed to incur no change in external cost
during years one and two.
Filers phased in during year one: 8,315 x 26%. Average yearly change in external cost per filer: [$5 x 3 x
4.5] / 3 = $22.50. Aggregate average yearly change in external cost for filers phased in during year one:
8,315 x 26% x $22.50 = $48,643.
Filers phased in during year two: 8,315 x 19%. Average yearly change in external cost per filer: [$0 + $5 x
2 x 4.5] / 3 = $15.00. Aggregate average yearly change in external cost for filers phased in during year two:
8,315 x 19% x $15.00 = $23,698.
Filers phased in during year three: 8,315 x 55%. Average yearly change in external cost per filer: [$0 + $0
+ $5 x 4.5] / 3 = $7.50. Aggregate average yearly change in external cost for filers phased in during year
three: 8,315 x 55% x $7.50 = $34,299.
Aggregate average yearly change in external cost: $48,643 + $23,698 + $34,299 = $106,640.

10

8,315 x (-4) = -33,260 hours.

11

8,601 x 4.5 = 38,705 responses. 38,705 responses x 56 hours per response = 2,167,480 hours.

12

8,601 x 4.5 = 38,705 responses. 38,705 responses x $6,170 per response = $238,809,850.

13

8,315 x 4.5 = 37,418 responses. 37,418 responses x 56 hours per response = 2,095,408 hours.

14

8,315 x 4.5 = 37,418 responses. 37,418 responses x $6,170 per response = $230,869,060.

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companies will be 2,041,693 hours of in-house personnel time15 and $230,975,700 in the
cost of services of outside professionals,16 which represents a decrease of 53,715 hours of
in-house personnel time17 and an increase of $106,640 in the cost of services of outside
professionals18 or a decrease of 6.46 hours of in-house personnel time per filer19 and an
increase of $12.83 in the cost of services of outside professionals per filer.20
The differences between the estimates in connection with the Inline XBRL
Proposing Release and those in connection with the adopting release are due to our
updated estimate of the number of filers and an updated estimate of the percentage of
filers that will be phased in during each of year one, two and three. We previously
estimated that there would be 38,705 responses per year by 8,601 filers. We now
estimate that there will be 37,418 responses per year by 8,315 filers. We previously
estimated, based on staff analysis of Form 10-K filings during calendar year 2015, that
26% of filers would be phased in during year one, 18% during year two and 56% during
year three. In connection with the adopting release, based on staff analysis of Form 10-K,
10-Q, 20-F, and 40-F filings and amendments to them filed during calendar year 2017, we
estimate that 26% of filers will be phased in during year one, 19% during year two and
55% during year three.
The four tables immediately below illustrate, respectively, the changes in
 amounts previously approved by the Office of Management and Budget
(OMB) due to the adjustment needed to reflect an updated and lower
estimate of the total number of filers and, as a result, responses (Table 1);
 the adjusted estimates presented in Table 1 due to the program change
caused by the exercise of agency discretion to adopt the amendments
(Table 2);


previously approved burden hours due to the combination of the
adjustment and the program change (Table 3); and



previously approved professional costs due to the combination of the
adjustment and the program change (Table 4).

15

2,095,408 - 53,715 = 2,041,693 hours. See note 13 above and note 17 below.

16

$230,869,060 + $106,640 = $230,975,700. See notes 9 and 14 above.

17

-20,455 - 33,260 = -53,715 hours. See notes 8 and 10 above.

18

See note 9 above.

19

-53,715 hours / 8,315 filers = -6.46 hours per filer. See note 17 above.

20

$106,640 / 8,315 filers = $12.83 per filer. See note 9 above.

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Table 1 - Summary of the Changes to Annual Compliance in Collection of Information
Due to Adjustment to Reflect Updated Estimate of Total Number of Filers

Interactive Data

Previously
Approved
Annual
Responses
(A)

Adjusted
Annual
Responses
(B)

Previously
Approved
Burden
Hours
(C)

Increase in
Burden Hours
(D)

Adjusted
Burden Hours
(E)
=C+D

Previously
Approved
Professional
Costs
(F)

Increase in
Professional Costs
(G)

Adjusted
Professional
Costs
=F+G

38,705

37,418

2,167,480

(72,072)

2,095,408

$238,809,850

$(7,940,790)

$230,869,060

Table 2 - Summary of the Changes to Annual Compliance in Collection of Information
Due to Program Change Resulting from Agency Discretion

Interactive Data

Adjusted
Annual
Responses
(A)

Requested
Annual
Responses
(B)

Adjusted
Burden
Hours
(C)

Increase in
Burden Hours
(D)

Requested
Burden Hours
(E)
=C+D

Adjusted
Professional
Costs
(F)

Increase in
Professional Costs
(G)

Requested
Professional
Costs
=F+G

37,418

37,418

2,095,408

(53,715)

2,041,693

$230,869,060

$106,640

$230,975,700

Table 3 - Summary of the Changes to Previously Approved Burden Hours Due to
Combination of Adjustment to Reflect Updated Estimate and Program Change Resulting
from Agency Discretion

Interactive Data

Previously
Approved Burden
Hours
(A)

Increase in Burden
Hours Due to
Adjustment
(B)

Increase in Burden
Hours Due to
Program Change
(C)

Total Net Increase in
Burden Hours
(D) =B+C

Requested Burden
Hours
(E)
=A+D

2,167,480

(72,072)

(53,715)

(125,787)

2,041,693

Table 4 - Summary of the Changes to Previously Approved Professional Costs Due to
Combination of Adjustment to Reflect Updated Estimate and Program Change Resulting
from Agency Discretion

Interactive Data

14.

Previously Approved
Professional Costs
(A)

Increase in Professional
Costs Due to
Adjustment
(B)

Increase in
Professional Costs
Due to Program
Change
(C)

Total Net Increase in
Professional Costs
(D) =B+C

Requested Professional
Costs
(E)
=A+D

$238,809,850

$(7,940,790)

$106,640

$(7,834,150)

$230,975,700

COSTS TO FEDERAL GOVERNMENT

We estimate that the cost of preparing the amendments is approximately
$100,000.

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15.

REASON FOR CHANGE IN BURDEN

As explained in further detail in Items 12 and 13 above, the changes in burden are
due to an updated estimate of the number of filers and the amendments adopted in
Release No. 33-10514. The amendments implement changes to require the use of the
Inline XBRL format in place of the currently required exhibit-only submission of
operating company financial statement information in Interactive Data Files and also
eliminate the requirement to post the operating company financial statement information
Interactive Data File on the company’s website, if any.
The resulting changes in burden of Interactive Data due to the updated estimate
are lower hourly and professional cost burdens. These lower burdens are due to more
recent information indicating a lower number of filers.
The resulting changes in burden of Interactive Data due to the amendments are a
lower hourly burden and higher professional cost burden. The lower hourly burden is due to
less time being needed to prepare an Interactive Data File in Inline XBRL format than in
exhibit-only format and the elimination of the website posting requirement. The higher
professional cost burden is due to additional assistance or software needed to prepare an
Interactive Data File in Inline XBRL format as compared to exhibit-only format.

The purpose of requiring the use of Inline XBRL format for the submission of
operating company financial statement information is to improve the usefulness and
quality of financial statement disclosure, and, over time, decrease the cost of preparing
this information for submission to the Commission.
See attached short statement.
16.

INFORMATION COLLECTION PLANNED FOR STATISTICAL PURPOSES
The information collection does not employ statistical methods.

17.

APPROVAL TO OMIT OMB EXPIRATION DATE
The Commission is not seeking approval to omit the expiration date.

18.

EXCEPTIONS TO CERTIFICATION FOR PAPERWORK REDUCTION ACT
SUBMISSIONS

There are no exceptions to certification for the Paperwork Reduction Act
submission of which this supporting statement is a part.
B.

STATISTICAL METHODS
The information collection does not employ statistical methods.

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INTERACTIVE DATA SHORT STATEMENT
The amendments adopted in Release No. 33-10514 will require the use of the Inline
XBRL format for the currently required exhibit-only submission of operating company financial
statement information using the machine-readable (i.e., interactive) eXtensible Business
Reporting Language (XBRL) format in Interactive Data Files. These amendments will require
operating companies, on a phased in basis, to embed part of the Interactive Data File within an
HTML document using Inline XBRL and include the rest in an exhibit to that document. The
primary purpose of these amendments is to improve the usefulness and quality of financial
statement disclosure, and, over time, to decrease the cost of preparing this information for
submission to the Commission. In addition, the amendments eliminated the requirement for
operating companies to post Interactive Data Files on their websites. Also, the amendments will
make and have made certain other changes not affecting operating companies. For purposes of
the PRA’s aggregate average yearly burden, we estimate that the amendments affecting the
Interactive Data collection of information will result in a decrease of 53,715 burden hours and an
increase of $106,640 in the cost of the services of outside professionals. The lower hourly
burden is due to less time being needed to prepare an Interactive Data File in Inline XBRL format
than in exhibit-only format and the elimination of the website posting requirement. The higher
professional cost burden is due to additional assistance or software needed to prepare an
Interactive Data File in Inline XBRL format as compared to exhibit-only format.